General Compliance Program

Sinnamas Investment Bank & Capital Trust (“SINNAMAS”) and each of its majority-owned subsidiaries (together with SINNAMAS, the “GROUP”) are firmly committed to participating in international efforts to combat money laundering and the funding of terrorist activities.

SINNAMAS is a Connecticut registered investment bank and statutory trust company headquartered in Melaka, in Malaysia. The GROUP has implemented a risk-based global Anti-Money Laundering ("AML") Compliance Program (“AML Program”) designed to comply with AML laws and regulations in the U.S., including the Bank Secrecy Act, as amended by the USA PATRIOT Act of 2001, the Anti-Money Laundering Act of 2020, and other applicable laws and regulations relating to the prevention of money laundering and terrorist financing in the jurisdictions where the GROUP operates. The AML Program consists of, among other things:

  • Designations of a Global Head of Financial Crimes Compliance and sector, regional, and legal entity AML Compliance Officers who are responsible for coordinating and monitoring day-to-day compliance with the AML Program for their businesses and regions, respectively;

  • AML risk assessments at the program, customer, and product and services levels;

  • Written policies, procedures, and a system of internal controls designed to facilitate ongoing compliance with applicable AML laws and regulations;

  • Know Your Customer standards including a Customer Identification Program and Customer Due Diligence procedures reasonably designed to identify and verify all customers and, where applicable, beneficial owners, source of funds, and the nature and intended purpose of the business relationship, to the extent warranted by the risk of money laundering or terrorist financing or as required by regulation;

  • Performance of additional due diligence on higher risk customers, including correspondent banking and private banking customers and those who are assessed to be politically exposed persons;

  • Risk-based measures and systems for ongoing monitoring of transactions and activities through customers' accounts;

  • Identification and reporting of suspicious transactions or activities to appropriate regulatory authorities in accordance with applicable laws;

  • AML training for appropriate personnel; No. 22-1 Jalan Mp10, Taman Merdeka Permai, Batu Berendam, Melaka, Melaka (MY-04), 75350, MALAYSIA.

  • Independent audit and compliance testing functions to review and assess the GROUP for compliance with the AML Program and applicable laws;

  • Prohibition from conducting business with shell banks; and

  • Record keeping and reporting requirements, including those for cash transactions and records obtained pursuant to the Customer Identification Program, which are maintained for at least five years after the termination of a customer relationship.

 

The GROUP follows the regulations administered by the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC") and has implemented policies and procedures designed to comply with the prohibitions and restrictions mandated by OFAC and all other sanctions laws and regulations applicable in the jurisdictions where the GROUP operates.


The GROUP has a zero-tolerance approach to tax evasion and the facilitation of tax evasion. The GROUP has implemented policies and proportionate, reasonable prevention procedures against facilitation of tax evasion, including the requirements to conduct periodic risk assessments, to undertake product due diligence and training, and to implement escalation procedures.

Compliance with the legal and regulatory requirements that govern the management of client relationships is critical for the GROUP to protect itself and the international financial system from the abuses of illicit finance. Moreover, compliance with our AML Program and internal procedures allows us to maintain good standing in the jurisdictions in which we transact business. The GROUP cooperates to the fullest extent permitted by law with investigations and inquiries from law enforcement and regulatory authorities.